ACCURATE’s UOCAVA Pilot Program Comments

As we described earlier this week, the Election Assistance Commission is developing a new voting systems testing and certification regime geared towards pilot voting systems–that is, experimental voting systems intended for limited use in designated pilot program elections, with specific standards, testing and certification. (On Monday, ACCURATE submitted comments on the administrative infrastructure for this new regime.)

Today, ACCURATE submitted comments on the first such pilot program under the new system, geared towards UOCAVA voters. This pilot program is a joint collaboration between FVAP, NIST and EAC, under the MOVE Act, that seeks to provide “kiosk” voting systems for a federal election for UOCAVA voters.

It’s an ambitious undertaking, and the draft standard reflects a great deal of work towards setting requirements to which voting systems can be tested and certified to provide UOCAVA voting capacity. ACCURATE’s comments break down like so:

  • The focus on controlled, supervised voting system architectures is appropriate. Many of the fundamental problems with forms of Internet voting are associated with uncontrolled platforms–users PCs, mobile devices, etc.–in unsupervised environments–i.e., at home instead of a dedicated polling place-like environment. The requirements restrict voting systems to dedicated platforms in supervised environments, short-circuiting this concern with broader efforts at Internet voting.
  • The requirement for a Voter-Verified Paper Record (VVPR) is warranted. ACCURATE strongly believes that auditability achieved through an independent, indelible audit trail that the voter has an opportunity to correct is an essential part of computerized voting system integrity. The Draft calls for such a record, in the form of a paper record. However, we feel the need to point out that VVPRs are not terribly useful unless audits are conducted using these records to provide regular checks on the correct functioning of the voting system.
  • The usability and accessibility requirements need work. ACCURATE noted that there are no accessibility requirements in the Draft and the usability requirements seem hastily assembled from a previous standards effort. In our comments, we discuss how attention to usability and accessibility is key during the development stages of new technology and go on to recommend that some additional usability testing and requirements be added to the draft.
  • There have been significant improvements in security specification and testing. The Draft does a good job at improving upon some of the security specifications and testing that we have seen in the past. We are encouraged to see threat modeling and penetration testing adopted in the draft requirements and we recommend a few changes that would make them even stronger.

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